When Policy and Care Collide: Part One

Balancing Patient Consent with Patient Safety

By the EHR Association Patient Safety and Public Policy Leadership Workgroups

Navigating the tug-of-war between federal and state regulations has long been a challenge in health care and other industries. Now, with the ubiquity of health data creating both new opportunities and risks, that challenge has never been greater. This dual framework requires healthcare organizations and their technology partners to track and balance confusing and sometimes conflicting compliance efforts, adding administrative burden to the system as a whole and, in some cases, increasing the risk of adverse patient safety events.

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Cybersecurity Awareness Month: Key Cybersecurity Controls and Practical Challenges

By the EHR Association’s Privacy & Security Workgroup

Health care faces several security risks that make a focus on cybersecurity particularly critical. In particular, the industry is challenged by dual threats: highly valuable patient data (worth more on the black market than financial data at this point) and system interdependencies that directly introduce additional risk. A single cyber incident can disrupt hospital operations, delay treatments, and even jeopardize patient safety. 

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Cybersecurity Awareness Month 2025: The State of Healthcare’s Cybersecurity

By the EHR Association’s Privacy & Security Workgroup

Healthcare cybersecurity risks have surged to unprecedented levels over the 22 years since the HIPAA Security Rule was first implemented—and the 12 years since its last update. 

According to the HIPAA Wall of Shame,  of the 614 data breaches reported in 2013, 43% (269) affected the healthcare industry. That was the first year since 2005 that the healthcare sector ranked higher than business in terms of the number of data breaches. At 9 million, healthcare also recorded the second-highest number of affected individuals. 

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EHRA Statement on 2025 Cybersecurity Awareness Month

October is Cybersecurity Awareness Month. The 2025 theme is “Building a Cyber Strong America,” highlighting the need to strengthen the country’s infrastructure against cyber threats and ensure resilience and security. In recognition of healthcare’s rising threat profile and the urgent need to shore up cybersecurity industry-wide, the EHR Association shares the following statement:

Cybersecurity Awareness Month is an ideal opportunity to highlight the healthcare industry’s unique security risks, in particular the dual threat we collectively face from the highly valuable patient data held in our health IT systems, as well as the critical dependencies that directly impact patient care. Health data is a top target for nefarious actors, and a single cyber incident can cause lasting harm by disrupting operations, delaying treatments, and jeopardizing lives. To reduce the industry’s risk profile, the EHR Association advocates for stronger protections and realistic, risk-based implementations of security safeguards that enhance resilience without overwhelming resource-constrained hospitals, health systems, and other provider organizations.

– EHR Association Privacy & Security Workgroup

HIPAA Security Rule Part Three: Risk-Based and Industry-Aligned Approaches Recommended

By the EHR Association Privacy & Security Workgroup

This three-part blog series shares the EHR Association’s stance on OCR’s proposed changes to the HIPAA Security Rule. Part one focused on our overarching concerns and issues with proposed definitions. Part two and this installment highlight our concerns with OCR’s proposed expectations. 

The HIPAA Security Rule is overdue for modernization, given the rapid pace of technological change and increasing cybersecurity threats. While we support OCR’s intent to strengthen protections for electronic protected health information (ePHI), our analysis of the HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information raised concerns and questions we hope will be addressed before finalization.

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HIPAA Security Rule Part Two: Proposed Changes Require Clarity, Flexibility

By the EHR Association Privacy & Security Workgroup

This three-part blog series shares the EHR Association’s stance on OCR’s proposed changes to the HIPAA Security Rule. Part one focused on our overarching concerns and issues with proposed definitions. Part two focuses on several of the proposed standards.

Our analysis of proposed changes to the existing HIPAA Security Rule, released as HIPAA Security Rule to Strengthen the Cybersecurity of Electronic Protected Health Information, revealed a mixed bag of positive changes and areas of concern. In the first installment of this blog series, we noted the EHR Association’s appreciation for its enhancements to the cybersecurity baseline. However, we expressed concern about the resources and costs required for regulated entities to comply with the overhauled mandates. We also reviewed the feedback we shared with OCR on its proposed changes to key definitions.

In this installment, we highlight our concerns with several of OCR’s proposed expectations, drawing attention to the need for greater clarity and offering recommendations to ease compliance burdens while achieving intended outcomes. 

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